Workshop V Successful Integration into Established Environmental - - PDF document

Workshop V

Successful Integration into Established Environmental Program

Tuesday, March 26, 2019 3:30 p.m. to 4:45 p.m.

Biographical Information

Anita Evenson, Senior Consultant, Trinity Consultants, Inc. 1717 Dixie Highway Suite 900, Covington, Kentucky (859) 341-8100 x 116 aevenson@trinityconsultants.com Anita serves as a senior consultant in Trinity’s Covington/Greater Cincinnati office as an experienced air permitting and compliance expert with more than 15 years of high-level performance in the environmental consulting and engineering fields. This includes project management and technical experience in air quality permitting, emission inventories, regulatory compliance support, multi-media environmental assessments, and complex permitting compliance efforts surrounding CAM plans, several MACTs, Title V renewals, synthetic minor permits (including NSR and PSD analysis), and other engineering

• projects. Routinely assists clients in complying with complex environmental regulations.

Develops air emission inventories for plastics, resins, coating, steel mills, automotive, food and flavoring clients that involves site evaluations, process analysis, extensive records review, and detailed calculations of potential and actual emissions. Anita is a graduate of Rose-Hulman Institute of Technology with a B.S. in Chemical Engineering. Hannah Fanzini, Environmental Engineer SABIC Innovative Plastics Mt. Vernon, LLC 1 Lexan Lane, Mt. Vernon, Indiana 47620 (812)831-7047 Hannah.Fanzini@sabic.com Hannah started her environmental career with SABIC Innovative Plastics in August 2011 as a engineering co-op student. During her undergraduate career, she progressed through 5 rotations across plant site within production units. After graduation, she joined SABIC Innovative Plastics in Mt. Vernon, Indiana in 2015 with the Rotational Engineering Program (SEeD). These rotations covered production, process, reliability, and EHS roles across two SABIC sites in Alabama and Indiana. Some of her projects include creating process control narratives, orchestrating the replacement of obsolete PLC’s on a critical system, and leading the start-up phase for the site Cogeneration CEMS/DAHS. In 2017, Hannah joined the environmental team at the Mount Vernon. Her primary responsibilities for include supporting operations to comply with the site NPDES permit, CERCLA/EPCRA, and the site infrastructure section of the Title V permit. Hannah is a graduate of Purdue University with a B.S. in Chemical Engineering.

Biographical Information

Tuyen Nguyen, Senior Environmental Engineer SABIC Innovative Plastics Mt. Vernon, LLC 1 Lexan Lane, Mt. Vernon, Indiana 47620 (812)831-7539 Tuyen.Nguyen@sabic.com Tuyen’s environmental career began in 1992 as a Waste and Air Compliance

• Coordinator. She went on to gain extensive experience in environmental, health, and

safety management that includes over 20 years of combined experience in the private and governmental sectors utilizing technological and methodological advancements to ensure better compliance results. Tuyen joined SABIC in Mt. Vernon, Indiana in 2015 as a Senior Environmental Engineer. Tuyen’s areas of expertise range from management and support operation site to comply with Title V permit requirements, the implementation of standards, performance and prevention in Environmental, Health, and Safety function according to federal environmental laws and industry standards, and leading team efforts in various initiatives. Tuyen is a graduate of University Louisiana of Monroe with a B.S. in Toxicology and minor in Chemistry. Jennifer Thompson, Partner, Bingham Greenbaum Doll LLP 2700 Market Tower 10 West Market Street, Indianapolis, Indiana 46204 (317) 968-5305 jthomspon@bgdlegal.com Jennifer is a partner in the Firm's Environmental Practice Group. She has practiced environmental law for over twenty years with experience both in the public and private

• sector. She provides environmental legal services to industrial, commercial, agricultural

and governmental clients. Services include compliance and transactional assistance, regulatory analysis, defense of enforcement actions, assistance in obtaining, negotiating, and appealing environmental permits, and assistance with contaminated properties.

March 27, 2019 S ession V

S uccessful Integration into an Established Environmental Program

Introductions

Anita Evenson – Senior Consultant

˃ Trinity Consultants Covington, KY / Greater Cincinnati

• ffice

˃ Overview of environmental programs ˃ Recordkeeping best practices

Tuyen Nugyen – Senior Environmental Engineer

˃ S

ABIC Innovative Plastics Mt. Vernon, LLC (S ABIC)

˃ Regulatory programs at S

ABIC

˃ Experience brought from other industries

Introductions

Hannah Fanzini – Environmental Engineer

˃ S

ABIC

˃ Experience at multiple S

ABIC facilities

˃ Co-op and new graduate

Jennifer Thompson – Partner

˃ Bingham Greenbaum Doll LLP ˃ Experiences of clients changing roles ˃ S

topping knowledge loss during transitions

Introductions

Anita Evenson– Senior Consultant

˃ S

tarted at Trinity December 2017 via acquisition of QS EM

˃ Experience serving a wide range of industries and clients

across Indiana and Ohio

˃ B.S

. Chemical Engineering Rose-Hulman

˃ Based out of the Covington, KY / Greater Cincinnati office

1717 Dixie Hwy, Suite 900

Covington KY 41011 Office: (859) 341-8100 x 116 Cell: (513)391-0521 aevenson@ trinityconsultants.com

Evolution of Trinity Consultants

1974

˃ One person, one office ˃ Air quality specialty

2018

˃ Approximately 600 employees ˃ 55 offices in North America,

Europe, China, and the Middle East

˃ S

erve more than 2,500 clients annually

˃ EHS

consulting services with a focus on air quality

˃ IS

O 9001-based Quality Management S ystem, certified in Dallas, TX

˃ ~35%

Employee owned

Trinity’s Services

˃EHS

Regulatory Consulting

Air quality services

♦Air permitting and compliance ♦Air dispersion modeling ♦S

• urce testing/emissions monitoring

support

♦Ambient and meteorological monitoring

Waste management

♦Industrial and solid waste management ♦Beneficial use and alternate fuels

Water quality services

♦Water quality permitting and compliance ♦Water monitoring, sampling, and

treatment analyses

 NEP

A/ EIA support

 Noise and odor analysis  Risk Management

Planning/ Process S afety Management (RMP/ PS M)

 Environmental reporting  Industrial siting  Client advocacy  Litigation support  Professional Training  EHS

Performance & Risk MGMT

7

Presentation Agenda

˃ Trinity

 Resources  Regulatory programs  Recordkeeping best practices

˃ S

ABIC

 Transitioning between industries  Reporting system  Understanding regulations  Learning on the j ob

˃ BGD Legal

 Misconceptions of established environmental programs

The Big Picture

Program Administration Federal Laws & Regulations U.S. Environmental Protection Agency State Laws & Regulations State Agencies (IDEM, OH EPA, KY DEP) Permits Enforcement/ Compliance

Facility Resources

˃ Internal ˃ Corporate ˃ Environmental

management system

˃ File review at local/ state

level

Federal Resources

˃ Environmental Compliance History Online

(ECHO)/ Envirofacts

˃ Federal Register (FR) ˃ Electronic Code of Federal Regulations (eCFR) ˃ TRI Explorer ˃ RS

EI Model

Ohio Digital Resources

˃ Electronic permits ˃ Engineering Guides ˃ Ohio eBusiness

Indiana Digital Resources

˃ Electronic permits ˃ Virtual Filing Cabinet ˃ Electronic reports

 EMITS  Tier II Manager  NetDMR

Kentucky Digital Resources

˃ New website and forms ˃ KY One S

top Business Portal

 Electronic S

ubmittals

 EEC eForms

˃ DEP S

earch Online

 Permit status  Rules under review

˃ NetDMR

Louisville Digital Resources

˃ Louisville Metro Air Pollution Control District

“ The District”

˃ S

eparate regulatory entity

˃ Title V permits online ˃ No electronic submittal portal

Regulatory Environmental Programs

˃ What programs

apply to my facility?

˃ How are programs

managed?

˃ Overlap between

programs.

Air Regulatory Programs

˃ Title V facility ˃ S

ynthetic minor source

˃ Minor source ˃ Permit-by-

rule/ exemption

Wastewater Regulatory Programs

˃ Individual ˃ General ˃ S

tormwater

˃ No exposure

Waste Regulatory Programs

˃ Hazardous Waste Generators Improvement Rule ˃ Hazardous waste category ˃ Keys to compliance

 Recordkeeping  Training

Facility Plans

˃ S

PCC- S pill Prevention, Control, and Countermeasure Plan

˃ S

WPPP- S tormwater Pollution Prevention Plan

˃ FRP- Facility Response

Plan

˃ RMP- Risk Management

Plan

Community-Right-to-Know Programs

˃ S

ection 302 Emergency Planning Notification

˃ S

ection 311 S DS reporting

˃ S

ection 312 Inventory (Tier I/ II) Reporting

˃ S

ection 313 Toxic Release Inventory Reporting (TRI)

Site-Specific Compliance Calendar

˃ Crucial to environmental compliance ˃ Include all permit requirements ˃ Components maybe out of your control ˃ Plan extra time for agency submittals

 S

ignatory availability

 S

ystems down

˃ Environmental management systems

Site-Specific Deadlines

˃ Emergencies/ Malfunctions ˃ S

ampling requirements

˃ S

pills/ Releases

˃ Renewals

Questions to Ask DAILY

˃ Do you know if you are doing

everything you are supposed to be doing?

˃ Can you prove you are doing

everything you are supposed to be doing?

˃ Is all of your compliance

documentation easily accessible?

Record Keeping

˃ File retention ˃ Format ˃ What to keep?

 Notifications & reports  Testing & monitoring data  Maintenance data  Corrective action data

Recordkeeping Best Practices

˃ Centralized system ˃ Use EMS ˃ Involve operators

 Train  Assign roles

˃ Date stamp & sign incoming mail ˃ QA all records

SABIC Innovative Plastics Mt. Vernon, LLC

28

Classification: Internal Use

Current Role

• Sr. Environmental Engineer

Air Permitting RC14001 Normal daily tasks Air permit compliance Regulatory reporting Education University of Louisiana Monroe B.S. Toxicology 1992 Past Experience Environmental Manager July 2002 ‐ December 2014 Environmental Supervisor July 2002 ‐ December 1998 Environmental Engineer Aug 1992 ‐ July 2002 TUYEN NGUYEN – SENIOR ENVIRONMENTAL ENGINEER

29

Classification: Internal Use

LARGE SCALE, GLOBAL PRODUCER

Everyday MTV makes enough plastic pellets to fill 16 railcars (the equivalent of 75 tractor trailer loads)

30

Classification: Internal Use

BROAD PORTFOLIO PRODUCED AT MTV

LEXANTM resins Clarity, superior flow-heat-impact balance, & dimensional stability XENOYTM, VALOXTM and XYLEXTM resins Chemical resistance & excellent impact performance Environmentally sustainable grades ULTEMTM and EXTEMTM resins Superior heat resistance & mechanical strength CYCOLOYTM resins Optimum flow-heat-impact-stiffness balance, & dimensional stability Functional Forms LEXAN film/sheet & MARGARDTM sheet High performance films & high impact sheet

31

Classification: Internal Use

INTEGRATION INTO EXISTING ENVIRONMENTAL PROGRAMS

• Simple Title V Air Permit
• One operation unit
• Minimal Federal Environmental

Regulation

• Recordkeeping (Paper and electronic

file)

• State Inspectors
• Complex Air Permit
• Multi‐ units at Facility
• Numerous Federal Environmental

Regulations

• Recordkeeping (Software and Electronic

file)

• State Inspectors

SHIPBUILDING MANUFACTURING PETROCHEMICAL MANUFACTURING

32

Classification: Internal Use

• Understand the lingo (TLA)
• Research process operations
• Shadow experience person
• Find documentation storage location
• Understand software and intent

TIPS FOR SUCCESS

33

Classification: Internal Use

• Focus on continuous improvement to

provide a safe place to work, protect the environment and be a responsible neighbor in the community

• Employees volunteer thousands of hours

each year in several communities.

SABIC AND THE COMMUNITY

Making a positive impact in the community

• West Elementary Mentorship

Program

• Site makes up ~ 50% of the United

Way of Posey County’s annual campaign.

34

Classification: Internal Use

HANNAH FANZINI – ENVIRONMENTAL ENGINEER

Current Role Environmental Engineer Air and Water Permitting CERCLA/EPCRA Normal daily tasks Utilities compliance Regulatory reporting Education Purdue University B.S. Chemical Engineering 2015 Past Experience 5 Term Co‐Op Rotations Engineering Program Rotations Production Role ‐ Brine Recovery Projects Role ‐ Process Controls EHSS / PS&E Reliability

35

Classification: Internal Use

• Chemical Operations
• Compounding
• Utilities

SITE EXPERIENCE

36

Classification: Internal Use

CEMS/DAHS REGULATORY REQUIREMENTS

Certification

• Cogen – 40 CFR 75
• Auxiliary Boilers – 40 CFR 60

Operation Pursuant to 40 CFR 60

• Cogen – Subpart KKKK
• Auxiliary Boilers – Subpart Db

37

Classification: Internal Use

LEAD WEEKLY COGEN ENVIRONMENTAL MEETINGS

Covered Various Environmental Topics

• Equipment
• Reports
• Certification testing
• Operational Compliance

38

Classification: Internal Use

• Air Emission Regulatory Requirements
• eCFR
• Title V Permits
• NPDES Permit Renewal
• CERCLA/EPCRA
• Spill Reporting
• Hazardous Waste Report

KEY LEARNINGS AS NEW ENVIRONMENTAL ENGINEER

www.bgdlegal.com

SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM

Jennifer Kahney Thompson

March 26, 2019

www.bgdlegal.com www.bgdlegal.com

Jennifer Kahney Thompson

• Jennifer is a partner in the Firm's Environmental

Practice Group. She has practiced environmental law for over twenty years with experience both in the public and private sector. She provides environmental legal services to industrial, commercial, agricultural and governmental clients. Services include compliance and transactional assistance, regulatory analysis, defense of enforcement actions, assistance in obtaining, negotiating, and appealing environmental permits, and assistance with contaminated properties.

40

www.bgdlegal.com www.bgdlegal.com

• Bingham Greenebaum Doll LLP is a business law firm providing

transactional, economic development, litigation, tax and succession planning services to clients ranging from Fortune 500 global companies to smaller, regionally based organizations across a variety of industries and business sectors for more than a

• century. The Firm also provides estate planning and other

services to individuals and non‐profit organizations.

41

Bingham Greenebaum Doll LLP

www.bgdlegal.com www.bgdlegal.com

SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Company submitted timely reports, permit applications and

renewals but never dug deep.

• NPDES compliance sampling and reporting done incorrectly

for years.

• Different natural‐gas fired units were installed than

permitted.

• NPDES DMR submitted with incorrect sampling result

numbers.

• Emission Unit from other plant swapped out with Company’s

unit.

• Incorrect laboratory procedure used by lab for waste water

sampling.

42

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Company has never dealt with a major modification.
• Management may not be familiar with what constitutes

“construction”.

• Budget and Capital Expenditures.
• Time it takes to get a Title V or PSD Permit.
• Did not forsee the issues with treating the new or increased

effluent.

43

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Company is dealing with “new technology” and others have not

paved the way.

• No AP‐42 Factors
• No similar operations.
• Calculating PTE is challenging to determine permit

requirements.

• Risks of incorrectly permitting.

44

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Company is subject to a new NESHAP or other regulation.
• Details can be overwhelming.
• Compliance dates set in stone.
• Often requires big capital investment for controls.
• Planning is essential.

45

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Not all docket systems are created equal.
• Make sure you customize the alerts to the dates you want to

be notified, not the dates the former environmental manager had in the system.

• Make sure you include enough time to complete the report

and have it go through the management chain for signature/approval.

• Spread out reports that are due at the same time so you are

not trying to complete a number of them at the same time.

46

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Company has never experienced a major malfunction.
• Submit malfunction reports and any other notices/reports

required to agencies involved.

• OSHA may investigate.
• Determine if operations need to be shut down, explain

consequences of continuing operation with management.

• Review maintenance tasks to ensure activities address the

likely causes of past failures.

• Amend preventative maintenance accordingly.

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Reports were filed but are records kept?
• Keeping track of all those records.
• Where to send submittals.
• Filing system, keeping a separate regulatory file.

48

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Staff may not realize their impact on the company’s

environmental compliance.

• No one is perfect, mistakes have been made.
• Understand whose job is to do what in an effort to ensure

compliance, including purchasing and maintenance personnel.

• Ensure staff are suitably trained and competent.
• Ensure a continuous improvement culture.

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SUCCESSFUL INTEGRATION INTO AN ESTABLISHED ENVIRONMENTAL PROGRAM Misconceptions of an “Established Environmental Program”

• Always keep management apprised of situations that are

uncovered or that are developing.

50

Questions?

Anita Evenson aevenson@ trinityconsultants.com Office: (859) 341-8100 x 116 Cell: (513)391-0521 Tuyen Nguyen Tuyen.nguyen@ sabic.com Office: (812)831-7539 Hannah Fanzini Hannah.fanzini@ sabic.com Office: (812)831-7047 Jennifer Thompson j thompson@ bgdlegal.com Office: (317)686-5234